SFDR Disclosure

OQUENDO CAPITAL, SGEIC S.A. (“The Company”) generally integrates sustainability risks in the investment decisions of the funds managed by itself in accordance with its policy of integrating sustainability risks in investment decision-making process that is available above (the “Responsible Investment Policy”)

In particular, the Company takes into account adverse impacts on sustainability factors in its risk assessment process and their impact on the value of investments based on a procedure for the selection and monitoring of all its investments which is supported by the following principles: (i) legality (ie. in relation to anti-corruption and piracy measures), (ii) respect of human rights (ie. in matters of child labor or labor slavery), (iii) respect of working conditions in optimal health and safety conditions (ie. in relation to indicators of parity and diversity), (iv) respect of the environment (ie. in relation to the volume of harmful substances emissions to the environment or the consumption of natural resources) and (v) compliance with governmental regulations (ie. in relation to the use of independent directors or adequate remuneration of administrators)

For the identification and monitoring of the aforementioned criteria, the Company, among others, requests statements from the companies in which it invests, maintaining a follow-up with them through a questionnaire and promoting the implementation of ESG criteria in them.The Company has adopted a decision-making process that guarantees that each of the investment opportunities are rigorously evaluated before, during and after the investment by the funds managed by the Company in the invested companies, so that in the case they don’t meet the criteria set out in the Sustainability Policy, such investment is ruled out.

Thus, the KPIs that the Company takes into account can be divided into indicators regarding (i ‘) environment (environmental), such as energy efficiency or the level of CO2 emission, (ii’) social, including the percentage of women on the workforce and the production of healthy and safe goods, and (iii ‘) corporate governance (governance) taking into account the criteria of corruption and residence in tax havens.

The Company has taken into account when drafting and implementing the Responsible Sustainability Policy certain codes of responsible conduct of business, as well as internationally recognized norms and standards, listed in the Sustainability Policy, regarding due diligence and reporting, complying with the good practices that are included in them. Likewise, the Company’s actions are aligned with the long-term objectives of the Paris Agreement, having incorporated as a key element of its environmental indicators, among others, reduced or zero greenhouse gas emissions.

In line with the foregoing, the Company’s remuneration policy has been updated to reflect the impact of the integration of sustainability risks in the remuneration of the affected personnel.